Privacy Policy

1. Who We Are

suvarnabas operates as a private educational provider registered in Thailand. Our registered place of business is 67 Soi Thonglor 10, Khlong Tan Nuea, Watthana, Bangkok 10110. We may be contacted by telephone at +66 2 627 4938 or by email at [email protected].

We are the data controller for personal information collected through this website and through participation in our courses.

2. Information We Collect

2.1 Information you provide directly

When you make an enquiry, register for a course, or correspond with us, we may collect:

• Your full name and preferred salutation
• Your email address and telephone number
• The content of messages you send to us
• Course enrolment and payment information
• Information you share during consultations or sessions relevant to your learning

2.2 Information collected automatically

When you visit our website, certain data is recorded automatically by our servers and analytics tools:

• Your IP address and approximate geographic region
• Browser type, operating system, and device type
• Pages visited, time spent, and navigation patterns
• Referring website or search terms, where available

2.3 Sensitive information

Some of our courses address personal life circumstances such as separation, divorce, bereavement, or health challenges. Any personal information shared in this context is treated with heightened discretion and used solely to support your learning experience. We do not record or retain sensitive details beyond what you explicitly provide and what is necessary for course delivery.

3. How We Use Your Information

We use the personal information we hold for the following purposes:

• To respond to your enquiries and provide information about our courses
• To process enrolments, payments, and course administration
• To deliver educational materials, workbooks, and scheduled sessions
• To arrange individual consultations with teaching staff or specialist advisors
• To send course-related updates, scheduling information, and follow-up correspondence
• To improve the quality and relevance of our courses and website
• To comply with applicable Thai and international legal obligations

We do not use your personal information for unsolicited commercial marketing without your separate and explicit consent.

4. Legal Basis for Processing

Under Thailand's Personal Data Protection Act B.E. 2562 (PDPA) and, where applicable, the European General Data Protection Regulation, we process personal information on the following legal bases:

• Contractual necessity — processing required to fulfil a course enrolment or respond to a pre-contractual enquiry
• Consent — for optional communications, newsletter subscription, or sharing of testimonials
• Legitimate interests — for website analytics and improving our educational offerings, where these interests are balanced against your privacy rights
• Legal obligation — where we are required by law to retain or disclose certain information

5. Sharing of Information

We do not sell, trade, or transfer your personal information to third parties for their own commercial purposes. We may share information in the following limited circumstances:

• Service providers: We engage trusted third parties for services such as payment processing, email delivery, and website hosting. These parties are bound by confidentiality obligations and are permitted to process your data only as necessary to provide their services to us.
• Teaching specialists: For programs involving external specialists (such as the legal or healthcare advisors in our senior program), relevant information may be shared with those specialists solely for the purpose of your consultation.
• Legal requirements: We may disclose information if required to do so by a court order, regulatory authority, or applicable law.

Where information is shared with parties outside Thailand, we take steps to ensure appropriate safeguards are in place.

6. Data Retention

We retain personal information for as long as necessary to fulfil the purposes set out in this policy, and in accordance with our legal and regulatory obligations. In general terms:

• Enquiry correspondence is retained for up to two years from the date of last contact
• Enrolment and course records are retained for up to seven years following course completion, for accounting and legal purposes
• Website analytics data is retained in aggregated, anonymised form for up to three years

When information is no longer required, it is deleted or anonymised in a secure manner.

7. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to support its functionality and to understand how visitors use the site. For a detailed account of the cookies we use, the purposes they serve, and your options for managing them, please refer to our Cookie Policy.

You may adjust your cookie preferences at any time using the preference tool available on our website.

8. Your Rights

Under Thailand's PDPA and applicable international frameworks, you may have the following rights in relation to your personal information:

• Right of access: to request a copy of the personal information we hold about you
• Right to rectification: to request correction of inaccurate or incomplete information
• Right to erasure: to request deletion of your information, where no overriding legal basis applies
• Right to restriction: to request that we limit our use of your information in certain circumstances
• Right to data portability: to receive your information in a structured, commonly used format, where technically feasible
• Right to object: to object to processing based on legitimate interests or for direct marketing purposes
• Right to withdraw consent: to withdraw any consent you have given, without affecting the lawfulness of processing carried out prior to withdrawal

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days of receiving a verifiable request.

9. Security Measures

We maintain administrative, technical, and physical safeguards appropriate to the sensitivity of the information we hold. These include encrypted data transmission (HTTPS), access controls limiting data access to authorised staff, and periodic review of our data handling practices.

No method of electronic transmission or storage is entirely without risk. While we take reasonable precautions, we cannot warrant absolute security. In the event of a data breach affecting your rights or interests, we will notify you and the relevant authorities as required by law.

10. Children's Privacy

Our courses are designed for adults aged 40 and above. We do not knowingly collect or process personal information from individuals under the age of 18. If you believe that a minor's information has been submitted to us in error, please contact us and we will remove it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the services we offer. When we make material changes, we will update the "last updated" date at the top of this page. We encourage you to review this policy periodically.

Continued use of our website or services after a change has been posted constitutes acceptance of the updated policy.